NRC-89-0047, Application for Amend to License NPF-43,requesting Rev of Tech Spec Section 4.3.8.2.c to Allow One Time Extension

Application for Amend to License NPF-43,requesting Rev of Tech Spec Section 4.3.8.2.c to Allow One Time Extension

ML20236D820
Person / Time
Site:	Fermi
Issue date:	03/10/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236D822	List: ML20236D901 NRC-89-0047, Application for Amend to License NPF-43,requesting Rev of Tech Spec Section 4.3.8.2.c to Allow One Time Extension
References
CON-NRC-89-0047, CON-NRC-89-47 NUDOCS 8903230290
Download: ML20236D820 (8)

Text

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• - B. Ralph Sylvia ,

Senor Vice President ,  !

. Detroit Edison ,W=",,

% ,m o, n ,

y March-10, 1989 NFC-89-0047 U. S. . Nuclear Regulatory Commission.

Attn Docunent Control Desk Washington,D. C. 20555  !

References:

1) Fermi 2 ,

NIC Docket No. 50-341. 1 NBC License No. NPF-43 1 l

Subject:

Proposed Technical Specification Change .

(License Amendment ) - Turbine Overspeed Protection System (3/4.3 8)

Pursuant to 10CFR50.90, Detroit Mison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating a one time surveillance extension into the Plant Technical Specifications.- Thin amendment requests revision of Technical Specification Section 4.3.0.2.c to  ;

allow a one time extension for the disassembly and inspection of the I turbine control valves, high pressure turbine stop valves, low pressure turbine intercept valves, and low pressure turbine stop valves until the first refueling outage, currently scheduled to begin in September 1989.

These tests will become overdue after May 20, 1989.

Detroit Faison has evaluated the proposed Technical Specification anendment against the criteria of .10CFR50.92 and determined that no significant l

hazards consideration is involved. The Fermi 2 Onsite Review Organization

! has approvoi and the Nuclear Safety Review Organization has reviewed the proposed Technical Specification amendment and concurs with the' enclosed determinations.

In accordance with 10CFR50.91, Detroit FAison has provided a copy.of this letter to the State of filchigan.

8903230290 890310 PDR ADOCK 05000341) 3 .

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. q US NTC l 3/1d/89 ..

' NBC-89-0047 q Page 2 l l

If you have any questions, please contact Ms. Lynne Goodman at (313) l 586-4211. l i

l S.irrerely, ab Enclosure cc: Mr. A. B. Davis Mr. R. C. Knop Mr. J. Stang '

Mr. W. G. Rogers Supervisor, Mvanced Planning and Review Section Michigan Public Service Commission -

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.US NTO-3/10/89 NIC-89-0047 Page 3 I, B..PALPH SYLVIA, do hereby' affirm that the foregoing.

statements are based on facts and circumstances which are true and accurate.to'the best of my knowledge and <

belief.

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Yt2/ bdo B. RAIIH SYLiiA

' Senior Vice President i l

On thin /8 day of h%d" , 1989, before me pornonally appeared B. Ralph Sylvia, being.

first duly sworn and says that he ' executed the foregoing .

as his free act and deed.

Patricia L. Ibberts

$6 Na AA*b l Notary Public-Wyne County, MI - kting in

&nroe (bunty, MI Ny Ccmnission expires 1/20/92

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Enclosure to  ;

tHC-89-0047  ;

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DISCUSSION Ato SAFF11Y ANEYSIS This proposed amendment to'the Fermi 2 tbclear Power Plant Technical Specifications requests a one-time extension to the disassembly and inspection interval for the turbine overspeed protection system valves. l The valves involved include' the turbine control valves, high pressure i turbine stop valves, lcv pressure turbine intercept valves, and the low

.pressu:e turbine stop valves. ]

Technical Specification 4.3.8.2.c requires that every 40. months' at 'least one turbine controlLvalve, high pressure turbine stop, valve, low pressure turbine intercept valve, and low pressure turbine stop valve be.  ;

disassembled, and a visual and surface inspection' performed of the valve (

seats, disks, aM stems to verify no unacceptable flaws or excessive l corrosion is present. An Mditional 25 percent may be added to the 40 {

month interval por Technical Specification 4.0.2.a, resulting in a latest i due date on this surveillance of May 20, 1989.

l t Performance of the surveillance requires the plant to be shut down. It is '

I estimated that the dismantling and inspection of one turbine control valve',  ;

one high pressure turbine stop valve, and one low pressure turbine j intercept valve will take 1340 man hours each and one low pressure turbine i stop valve 485 man hours. There are no outages planned between now and.the  !

first refueling outage.

l A low power license was issued for Fermi 2 on flarch 20, 1985. Use of this  ;

date for the commencement of the surveillance interval results in the May '

20, 1989 maxinum due date. Initial criticality was achieved on June 21, 1985. Upon entry into operation Condition 2, Specification-4.3.8.2.c first ,

became applicable. The first turbine roll was performed on September 26, l 1985. By the commencement of the first refueling outage, the valves will.

have experienced operating conditions for approximately 24 months. 1 Normally, 2 full operating cycles of wear are experienced before this surveillance is due to be performed. Due to Fermi's exteMed startup test l program, the surveillance becomes due before completion of even the first operating cycle. Therefore, this one-time extension is needed.

The purpose of the surveillance is to. assess the condition of the. valves to verify that no unacceptable flaws or excessive corrosion will prevent. them from closing when needed to prevent an overspeed condition. Valve.

mechanical behavior during routine operation has been good. There is no indication that the valve seats have corroded which could be evidenced by problems in keeping the unit on the turning gear during startup preparations. The valves closed properly during the trip experienced February 26, 1989. Weekly, each of the valves is fully cycled. This test is unaffected by this proposed one-time exteasion of the dismantling surveillance. There have been no situations detected where the valves 1

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1 Enclosure to, MC-89-0047 Page 2' '

would not fully close that could be attributed to actual valve problems.

The current and past problens that have been experienced with turbine valves have been due to actuator, circuitry, or test problems, not valve degradation. The required dismantling and inspection of the valves is to find problems with the valves themselves.

A mechanical and the electrical overspeed trip systems were last successfully tested on August 7,1988. This testing confirmed that the turbine is protected from an overspeed coMition, as required by Technical Specifications. The manufacturer of the turbine, English Electric, was contacted on this matter. Their representative stated that they concur with the postponement of the inspection to the first refueling outage.

The basis of the Standard Technical Specification involves maintaining turbine overspeed protection to reduce the hazard of turbine missiles.

This function is also discussed in the Standard Review Plan Sections 3.5.1.3 and 10.2. The bases for the Fermi 2 Turbine Overspeed Protection System specification states in part " Protection from turbine excessive overspeed is not required to protect safety-related ccmonents, equipment, )

or structures. However it is included in order to inprove overall plant l reliability." Since the overspeed protection system is not needed to l Jrotect safety-related equipment or to safely shutdown in the event of a I turbine overspeed condition, extension of the surveillance interval cannot adversely affect safety-related equipment. A discussion of the turbine missile evaluation is contained in the Updated Final Safety Analysis l Report, Section 10.2.3.

The Standard Review Plan, Section 10.2 states that at approximately 3-1/2 year intervals, during refueling or maintenance shutdowns coinciding with the inservice inspection schedule required by Section XI of the ASbE Code for reactor components, at least one of each type of valve should be dismantled ard examined. Fermi 2's UFSAR Section 10.2.3 commits to this interval. NUREG-0798, the Fermi 2 Safety Evaluation Report, states that this program is acceptable and will be included in the Fermi 2 Technical Specifications. Thus, the anticipated interval involved performance approximately every 3-1/2 years during refueling outages or maintenance shutdowns coincident with the inservice inspection schedule. The inservice inspection schedule required by Section XI of the ASME Code initialized at comtercial operation, thus 3-1/2 years from this time would not be until the second refueling outage. The proposed one-time extension to the first refueling outage is definitely within the program reviewed as acceptable.

To summarize, there is no safety issue involved in extending on a one-time basis the surveillance interval for the dismantling and inspection of turbine valves until the first refueling outage because

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' Enclosure to '1

- NIC-89-0047 *

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Il o . all tests performed to date have indicated:no problems.with the . j

. valves themselves, 9 q o the total period of valve exposure to operating conditions is well within the expected number of months exposure anticipated,for' .]

. future surveillance intervals, given average availability, '

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l o the vendor has indicated agreement with the extension,. and , . d o protection. from turbine excessive :overspeed is not r.equir to '-

protect safety-related-conponents,_' equipment-or structures.;

SIGEFICANP IRZhlOS CGEiIDEIRTIGT u

In accordance with 10CFR50.92, Detroit IMison has made a determination that the proposed ' amendment involves no significant hazards ~ considerations. To make this determination, Detroit Edison nust establish that operation in accordance with the proposed amendment would not: '1) involve a significant ~ increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a l significant reduction in a margin of safety.

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1) The proposed change does not involve a significant increme in the probability or consequences of an accident previously evaluated. The turbine was first rolled on Septenber 26, 1985., The valves will have only experienced. operating conditions for approximately 24 months by the beginning of the first refueling outage. Therefore, in actuality, =l the valves will be inspected prior to accumulating the amount of wear presently permitted by the Technical Specification. This does not represent any increase in the probability of.an accident.

Additionally, the protection provided by the overspeed protection system is not needed to protect safety related conponents, equipment or structures from turbine missiles. - Since extending the first interval does nothing to the consequences of an accident, this change will not -

change the consequences of an accident. Thus, there:is no increase in-the probability or consequences of any accident previously. evaluated.

2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated. A-one-time extension to the. surveillance interval for turbine valve '

disassently and inspection does not create any new modes of operation or testing. The' weekly high pressure turbine stop, low pressure turbine stop, high pressure turbine control and low pressure. turbine ,!

intercept valves cycling surveillance .is not changed by this proposed l .

Enclosure to ,

l NIC-89-0047

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amendment. Therefore, no new or different kind of accident. from any j accident previously evaluated has been created. j

3) The proposed change does not involve a significant reduction in the l

margin of safety. As stated above, the valves will actually experience

less operating time between inspections than what is presently

permitted by Technical Specifications and the overspeed protection system is not needed to protect safety-related conponents, equipnent or -

structures from turbine missiles. Therefore, the margin of safety will not be reduced by approval of this change request.

ENVIRONENmL IWACT ..

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Detroit R11 son ~ has reviewed the proposed Technical Specification change against the criteria of 10CFR51.22 for environmental considerations. The j proposed change does not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical-Specification change does meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Inpact Statement.

C0K10SION 1

i Based on the evaluation above: 1) there is reasonable assurance that the l l

health and safety of the public will not be endangered by the one-time extension, and 2) such activities will be conducted in conpliance with the Commission's regulations and the proposed amendnent will not be inimical to the common defense and security or to the health and safety of the public.

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